Fixed facility charges for specialised storage tanks, when included in the assessable value of supplied gases and subjected to central excise duty under the applicable Board circular, cannot additionally be treated as consideration for Supply of Tangible Goods Service. Although the tanks were supplied without transfer of effective possession and control, the charges had already borne excise duty as part of the gas value. Applying the departmental circular and the earlier determination concerning the same transactions, service tax, interest and penalties on those charges were unsustainable.

Banking investments classified as held to maturity require premium paid, including premium previously disallowed, to be amortised and deducted over their residual maturity period. Available-for-sale securities require mark-to-market valuation at the reporting date; the resulting loss is deductible. Where profit on sale of those securities has been taxed, the associated premium included in cost should not be disallowed. Deductibility of a leave-encashment provision under Section 43B(f) remains subject to the pending Supreme Court determination and requires fresh adjudication consistently with that determination.

Consideration from standard software sales and pure cross-charges for third-party software does not constitute royalty under section 9(1)(vi) of the Income-tax Act or Article 12(3) of the India-USA tax treaty where no taxable income element arises. Third-party hardware supplied to an Indian subsidiary on a cost-to-cost basis without mark-up is a reimbursement, not consideration giving rise to capital gains under the Act or Article 13 of the treaty. Software receipts and hardware reimbursements of this nature are therefore excluded from taxable income in India.

Reassessment initiated under section 148 for AY 2013-14 was time-barred because the alleged escaped income did not meet the threshold for extended action under the substituted reassessment regime. The initiating notice and consequential reassessment were therefore void ab initio. Separately, undisputed repayment of an unsecured loan, supported by bank records before reassessment proceedings, prevented the credit from being treated as unexplained cash credit and removed the basis for disallowing related interest. The reassessment and the loan-related adjustments were unsustainable.

Rectification is limited to errors apparent from the record and cannot resolve a debatable legal question. Whether MAT credit includes surcharge and education cess was subject to differing Tribunal views, including views favouring inclusion, so it could not be treated as an apparent mistake. Reduction of MAT credit through rectification was therefore invalid, and the credit allowed in the original scrutiny assessment remained available.

Timely electronic filing of Form 10B under Section 12A(b) is treated as a directory requirement, with delayed filing regarded as a curable procedural defect. In light of Circular No. 10/2019 and the debatable nature of the requirement, delay in uploading the audit report may be condoned. Exemption under Section 11 should not be denied during summary processing of a return under Section 143(1) solely because Form 10B was uploaded after the prescribed due date.

Documentary and banking evidence establishing creditor identity, financial capacity and transaction genuineness discharges the primary burden for unsecured loans; uncorroborated third-party reports, untested statements and unserved summons cannot sustain cash-credit additions without a live nexus, rebuttal evidence or cross-examination. The loan additions and consequential interest disallowances were therefore deleted. A bilateral English instrument lacking customary negotiable Hundi characteristics, where funds moved through banking channels, does not attract section 69D; the related addition was deleted. Business-loss carry-forward remains subject to verification of statutory eligibility, with eligible losses to be allowed.

In unabated assessments under sections 153A and 153C, additions concerning unsecured loans must rest on incriminating material found during the search and directly related to the proposed addition. Post-search enquiries, lender-related information and a standalone statement recorded during search do not supply that foundation. Seized records that merely reflect loans already recorded in regular books and disclosed in the original return are not incriminating. A notation suggesting repayment cannot establish cash repayment without corroborative evidence or lender enquiry. Accordingly, unsecured-loan additions cannot be sustained solely through post-search challenges to lender genuineness or cash-credit evidence.

Section 124(3) limits challenges to territorial jurisdiction but does not bar objections that an officer lacked inherent statutory authority to initiate reassessment. Statutory jurisdiction cannot be created by participation, acquiescence, or waiver; proceedings initiated without such authority are void. Section 151A and the faceless reassessment scheme require automated allocation and issuance of reassessment notices through the Faceless Assessing Officer, excluding concurrent jurisdiction of a Jurisdictional Assessing Officer. An order under Section 148A(d), notice under Section 148, and consequential assessment initiated outside that mandatory mechanism lack jurisdiction and are invalid.

Unexplained bullion claimed to have arisen from melted old jewellery remains unsubstantiated where post-search affidavits and subsequent jeweller confirmations do not identify the jewellery, specify the melting date, or provide contemporaneous records such as weighing slips and melting charges. CBDT jewellery limits applicable during search do not extend to bullion, particularly where the benefit has already been granted for jewellery found with family members. The bullion addition was therefore sustained as unexplained money under the Income-tax Act.

Section 54(1), as applicable to Assessment Year 2013-14, treated the expression "a residential house" as capable of covering qualifying investments in more than one residential property, including properties at different locations. The Finance (No. 2) Act, 2014 substitution of "one residential house" took effect from 1 April 2015 and did not restrict claims for the earlier assessment year. As a beneficial provision encouraging house purchase, Section 54(1) required liberal interpretation. Qualifying investments in Heritage One and Adani M2K were eligible for exemption, while the La Lagune claim depended on verification of the stipulated investment-time condition.

Registration under section 12AB requires examination of whether a trust's objects are charitable, including advancement of general public utility. Clauses benefiting members do not alone establish that the objects lack public benefit where the stated purposes include industry coordination, research, training, information dissemination, public infrastructure and community development. Section 13(1)(b) governs entitlement to exemption under sections 11 and 12 at assessment and, by itself, does not justify refusal of registration. The absence of religious objects and the overall public character of the purposes support fresh consideration of registration.

Addition for four 24-carat gold bars found in a locker remained sustained because concurrent findings treated them as unexplained and raised no substantial question of law under Section 260A. Gold ornaments in the locker were accepted as explained. The Section 260A challenge therefore did not warrant interference with the addition relating to the gold bars.

Contractual tax-allocation clauses treating tender prices as inclusive of taxes and barring claims arising from changes in tax structure place GST introduced after 1 July 2017 outside reimbursement, notwithstanding a specific provision concerning service tax. A disputed GST reimbursement claim arising solely from a private commercial contract, involving interpretation of contractual terms and factual questions, lacks the public-law element required for Article 226 review. Where the contract contains an arbitration clause, the claim must proceed through the agreed dispute-resolution mechanism or a competent civil forum rather than writ jurisdiction.

Review under Order XLVII Rule 1 of the Code of Civil Procedure is limited to an error apparent on the face of the record or an overlooked material fact affecting the decision. It cannot be used to reappreciate facts or reargue the merits. Where a writ claim has been treated as contractual and civil-court and arbitral remedies remain available, a review or recall request must identify an apparent error or other sufficient review ground. Grounds seeking only reconsideration on merits do not justify review or recall.

Engineering-export strategy development focuses on stronger use of free trade pacts, market access, competitive raw-material availability and resilient supply chains. Input-cost volatility, supply-chain disruptions, global overcapacity, trade-protective measures, sustainability-related requirements and climate-linked market-access conditions affect export competitiveness. Quality Control Orders require an evidence-based assessment of covered sectors and products, their rationale and industry impact, supported by a comprehensive white paper and panel-wide feedback for policy deliberation.

ITC differences between FORM GSTR-3B and FORM GSTR-2A for 1 April 2019 to 31 December 2021 must be assessed under the applicable rule 36(4) cap and the supplier-tax-payment condition. Additional unmatched ITC was restricted to 20% from 9 October 2019, 10% during 2020, and 5% during 2021, subject to verification and requisite certificates. Claims beyond the applicable cap are not admissible. From 1 January 2022, ITC requires supplier reporting in FORM GSTR-1 or through the Invoice Furnishing Facility and communication in FORM GSTR-2B.

Standard Input-Output Norm A-3718 governs manufacture of Clobetasol Propionate BP/EP/USP for export. It identifies Betamethasone 17-Propionate as the permitted import input for the specified export product and fixes the applicable input-output proportion. Applicants must ensure that goods sought to be imported, and goods actually imported, are those used or required in manufacturing the resultant export product.

Standard Input-Output Norm No. A-3717 under the Foreign Trade Policy fixes the permitted import input for manufacturing Doxycycline Tablets, USP 100 MG 500 S. For each unit of the export product, Doxycycline USP (Monohydrate) is specified at 109.68 mg. Applicants must ensure that goods sought for import and actually imported are used or required in the exported product.

Standard Input-Output Norm A-3716 fixes Doxycycline USP (Monohydrate) as the imported input for manufacturing Doxycycline Tablets, USP 100 MG 50 S. Applicants must ensure that imported goods are used or required in producing the specified export product.